1. ACE welcomes Government support for fuel poor households, but fears that in its proposed form, the Warm Home Discount is not a sensible use of resources. Government figures indicate that only 107,000 English households will receive direct help from the public purse to improve the energy efficiency of their homes over the next two years through Warm Front. That assists just 2% of those currently deemed to be in fuel poverty. The philosophy behind concentrating upon the Warm Home Discount is akin to running a bath with hot water, but omitting to put the plug in.

2. The Warm Home Discount would be vastly strengthened through integration with the Green Deal: encouraging the take-up of energy efficiency measures rather than providing cash rebates. It seems curious and inefficient that a household in fuel poverty could be receiving both measures subsidised by energy suppliers under the Energy Company Obligation tied to Green Deal, and a cash rebate from suppliers under the Warm Home Discount. Using the rebate to help allow more comprehensive energy efficiency packages that meet the ‘Golden Rule’ would offer a solution that alleviates fuel poverty more sustainably than perpetual cash rebates, as well as delivering energy and carbon savings. In this context it is worth noting that, as a direct result of ACE’s campaigning, Section 9 of the Energy Act 2010 was amended at Report Stage to include specific powers for energy suppliers to provide not just financial benefits to vulnerable consumers, but also benefits “in the form of goods or services”. These powers were included in the legislation with the clear intention that they be used by suppliers to offer energy efficiency packages – and not just cash rebates – to vulnerable customers.

3. We are alarmed by the proposal to reconcile costs between energy companies on the basis on customer numbers rather than on the basis of energy supplied. As set out in our answer to question 16, this is both regressive and runs counter to the ‘Polluter Pays’ principle. It also goes against the trend that suggested DECC were beginning to appreciate the benefits of having such environmental levies based on the amount of energy supplied. We urge DECC to reconsider this proposal.

4. We have confined ourselves to responding to those questions of relevance to ACE.